Business Continuity Plan

Harbert Management Corporation (“HMC”®) and its affiliated broker-dealer, HMC Investments, Inc., maintain a Business Continuity Plan (BCP) that has been developed to protect the health and safety of our employees and maintain continuity of service for our investors. The key elements of our BCP include the following:

We maintain an office evacuation plan and emergency procedures in the event of a disaster affecting our primary office facilities or surrounding area.

We maintain an emergency contact list and procedures which are updated and distributed on a regular basis.

The BCP is designed to address significant business disruptions of varying scope, including a firm-only disruption, single-building disruption, citywide business disruption, or a regional disruption. In the event of a significant business disruption, our employees would assemble at alternate business locations and access HMC’s computer data remotely. Key service providers would be contacted and would continue to provide critical processing for our investment transactions. Our key service providers maintain offices outside of New York City, and would not be affected by a New York City citywide business disruption. Even in the event of a regional disruption of significant scope, our key service providers maintain alternate business locations that permit them to resume critical functions in a reasonable period of time.

We cannot possibly forecast every potential problem that may occur, but we believe our BCP will enable us to continue to conduct business in the event of a variety of possible business disruptions. We believe that our BCP will help us to limit the recovery time necessary to resume operations.

We review our BCP at least annually. The BCP is subject to modification based on changing circumstances and assessment of need.